On February 4, 2014 and February 5, 2014, CMS offered the hospice industry an in-depth training on how to complete the Hospice Item Set (HIS) - something all hospices must do for every patient starting July 1, 2014. This was a tremendous service to those able to participate in person or via live streaming. The presentations are also available on demand from the following links:

I was very interested to watch the presentations. Quite frankly, I have not been paying as much attention to the Hospice Quality Reporting Program (HQRP) as I should. With a Weatherbee Hospice Regulatory Boot Camp coming up as well as deadlines related to the HQRP data submission on the horizon and the Hospice Item Set looming large I figured it was time to wrap my head around it more and understand it better.

HOLY COW!!!! As I sat there listening to the presentations both days, the following occurred to me:

Thanks Affordable Care Act (dripping with sarcasm). Even though I think the Affordable Care Act is a great thing, and that quality reporting is essential, the implementation of this is going to be very challenging!

There was lots and lots of emphasis on the fact that the Hospice Item Set is NOT an assessment tool. So the HIS is not the same as home health's OASIS but there sure are similarities.

I wonder who from hospice is listening? QAPI folks? Billing? Clinical managers/staff? Medical records folks? All of the above? (I hope)

More importantly, who in a hospice is going to abstract all this data from clinical records? Will hospices need to hire more people to do this?

How much work is going to need to be done by hospices to make sure their assessment / clinical tools are adequately capturing the data needed for the HIS?

Are all the EMR software vendors prepared to try to help their hospice clients manage this?

Is CMS completely unrealistic to think it will only take 19 minutes (14 for data and 5 for submission) to collect and submit the data for the Admission HIS record and 10 minutes (5 to collect and 5 to submit data) for the Discharge HIS record?

What kind of training will clinical staff need to ensure they are collecting all the required data elements in a standardized manner?

And then, of course, the big kahuna question - can hospices be ready to do this by July 1, 2014?

What do you think?

There will be another training in May on technical issues. In the meantime it would be a really good thing for hospices to have one or more people review the February trainings and get a good handle on the scope of what is required by the Hospice Item Set.

PS - And don't forget to submit the data you collected in 2013 by 11:59 April 1, 2014.